Two cornerstone authorities for federal contracting quietly expired on September 30, 2025, creating ripple effects that contractors—small and large—cannot afford to overlook. The Small Business Innovation Research/Small Business Technology Transfer (“SBIR/STTR”) programs, commonly known as “America’s Seed Fund” for their role in fueling early-stage innovation, and the Defense Production Act
Continue Reading Expired: SBIR/STTR and DPA Authorities in LimboDefense Industry
SBA Proposes Increasing 200+ Receipts-Based Size Standards
On Friday, August 22, 2025, the Small Business Administration (“SBA”) released a proposed rule to increase the size standard for what it considers to be a small business across 263 industries. The proposed rule principally covers receipts-based size standards. These proposed increases stem from SBA’s periodic review of size standards…
Continue Reading SBA Proposes Increasing 200+ Receipts-Based Size StandardsJuly 2025 AI Developments Under the Trump Administration
This is part of an ongoing series of Covington blogs on the AI policies, executive orders, and other actions of the Trump Administration. This blog describes AI actions taken by the Trump Administration in July 2025, and prior articles in this series are available here.
White House Issues AI…
Continue Reading July 2025 AI Developments Under the Trump AdministrationForging a Modern Strategic Production Base: Senate Proposes Stand-Alone Defense-Production Powers for the Pentagon
The Defense Production Act (DPA) has long been viewed as the primary federal mechanism for managing and supporting defense production. Since it was enacted in September 1950—just months after the Korean War began—the DPA has armed the President with wartime-style powers to prioritize contracts, allocate scarce materials, and finance surge defense production capacity. These DPA industrial authorities are subject to periodic reauthorization, with the current sunset set for September 30, 2025. While the reauthorization of the DPA remains pending, the Senate Armed Services Committee (SASC) has advanced a new NDAA provision that would convert the extant Industrial Base Fund (IBF) (10 U.S.C. section 4817) into a Pentagon-controlled toolkit that closely mirrors—but is not identical to—DPA’s Title III authorities. The introduction of section 849A of the FY 2026 NDAA suggests that the SASC is no longer willing to entrust the re-armament of the Pentagon and revitalization of the Defense Industrial Base (DIB) solely to reauthorization of the DPA—a process that lives or dies in other committees’ jurisdictions.
Continue Reading Forging a Modern Strategic Production Base: Senate Proposes Stand-Alone Defense-Production Powers for the PentagonTrump Administration Issues AI Action Plan and Series of AI Executive Orders
On July 23, the White House released its AI Action Plan, outlining the key priorities of the Trump Administration’s AI policy agenda. In parallel, President Trump signed three AI executive orders directing the Executive Branch to implement the AI Action Plan’s policies on “Preventing Woke AI in…
Continue Reading Trump Administration Issues AI Action Plan and Series of AI Executive OrdersFraud Prevention in Focus: Examining DOD’s Risk Management Strategies
The Department of Defense (“DOD”) is responsible for almost half of the federal government’s discretionary spending and spends more on contracting than all other federal agencies combined, obligating about $445 billion in fiscal year 2024. Given the renewed focus on fraud detection and prevention across the U.S. government – as highlighted both by the efforts of the Department of Government Efficiency (“DOGE”) and by recent congressional committee hearings focused on reducing waste, fraud, and abuse – the issue of fraud in DOD has become increasingly relevant.
On June 4, 2025, the House Committee on Oversight and Government Reform’s Subcommittee on Government Operations held a hearing titled “Safeguarding Procurement: Examining Fraud Risk Management in the Department of Defense,” during which congressional members examined strategies to combat fraud in DOD – including procurement fraud – and the steps the department is taking to address the problem.
Continue Reading Fraud Prevention in Focus: Examining DOD’s Risk Management StrategiesOne Big Beautiful Bill Act makes $150B investment in Defense
As part of the One Big Beautiful Bill Act (“OBBBA”) signed into law by the President on July 4th, Congress made approximately $150 billion in appropriations to support defense and national security priorities. As detailed further below, OBBBA touches on many different defense industries and sectors—including the maritime industry, missile systems, space and satellite technologies, nuclear technologies, and artificial intelligence and other advanced technologies. Further, the OBBBA appropriates significant funding to support strategic investments in the defense industrial base and provides the Department of Defense (“DoD”) with an extended timeline (until 2029) to execute these investments. Existing government contractors, and advanced technology providers interested in becoming contractors, should closely monitor the implementation of these OBBBA provisions, which will shape DoD opportunities for years to come.
Continue Reading One Big Beautiful Bill Act makes $150B investment in DefenseSPEEDing up Procurement?: House Armed Services Bill Seeks to Reform Defense Acquisition
The Trump Administration continues to focus on procurement reform aimed at increasing acquisition efficiency, including through the “Revolutionary FAR Overhaul” and reinforced preference for commercial products. Now, with the House Armed Services Committee (HASC) introducing a defense procurement reform bill, it is clear that HASC leadership is also targeting increased efficiency as a key goal of the Fiscal Year 2026 National Defense Authorization Act (FY26 NDAA). We cover the bill’s key proposals and their potential impact on defense contractors below.
Continue Reading SPEEDing up Procurement?: House Armed Services Bill Seeks to Reform Defense Acquisition
GAO: DCAA Built a Valuable Bench of Independent Public Accountants, Now What?
The Government Accountability Office (“GAO”) released a report on the Defense Contract Audit Agency’s (“DCAA”) past and future use of private-sector, independent public accountants to augment its auditor workforce. The initiative—approved under Section 803 of the Fiscal Year (“FY”) 2018 National Defense Authorization Act (“NDAA”)—began in fiscal year 2020 and was originally envisioned by Congress as a tool to reduce DCAA’s backlog of incurred cost audits. But, as GAO noted, DCAA had largely eliminated its audit backlog by the end of FY 2018, primarily through its reliance on risk-based sampling methodology, which reduced the number of audits DCAA was required to complete.
Continue Reading GAO: DCAA Built a Valuable Bench of Independent Public Accountants, Now What?
Reintroduced SHIPS Act Signals Continued Momentum for Domestic Maritime Investment
On April 20th, a bipartisan, bicameral group of lawmakers, including Senator Mark Kelly (D-Ariz.) and Senator Todd Young (R-Ind.) in the Senate and Representative John Garamendi (D-Calif.) and Representative Trent Kelly (R-Miss.) in the House, reintroduced the Shipbuilding and Harbor Infrastructure for Prosperity and Security for America Act of 2025 (the “SHIPS Act” or the “Act”). The SHIPS Act’s sponsors describe the bill as a “comprehensive approach to revitalizing the U.S. Merchant Marine.” It aims to: (1) establish national oversight and consistent funding for U.S. maritime policy; (2) make U.S.-flagged vessels more commercially competitive through de-regulation; (3) rebuild the U.S. shipyard industrial base; and (4) expand and strengthen the maritime labor force. It also sets a goal for establishing a fleet of 250 U.S.-flagged vessels in international commerce.
Continue Reading Reintroduced SHIPS Act Signals Continued Momentum for Domestic Maritime Investment